FIRE Shutdown Impact on 1098 Filers

Understanding the 1098 Series

The 1098 family of forms covers some of the most common tax-deductible expenses in the United States. Millions of these forms are filed every year by mortgage lenders, student loan servicers, and educational institutions. Here is a breakdown of the three primary 1098 variants:

• Form 1098 (Mortgage Interest Statement) — Filed by lenders who receive $600 or more in mortgage interest from a borrower during the tax year. Banks, credit unions, and mortgage servicers are the primary filers. Given the size of the U.S. mortgage market, this is one of the highest-volume information returns in the entire 1098 family.
• Form 1098-E (Student Loan Interest Statement) — Filed by student loan servicers who receive $600 or more in interest payments from a borrower. Both federal and private loan servicers must file. With over 43 million Americans carrying student loan debt, 1098-E filing volumes are substantial.
• Form 1098-T (Tuition Statement) — Filed by eligible educational institutions to report qualified tuition and related expenses. Colleges, universities, and vocational schools must file for each enrolled student who has qualifying transactions.

All three forms are currently filed electronically through the IRS FIRE (Filing Information Returns Electronically) system using fixed-width text files formatted according to IRS Publication 1220. When FIRE shuts down on December 31, 2026, that channel disappears permanently.

How FIRE Shutdown Affects 1098 Filing

The transition from FIRE to IRIS has been rolling out in phases. The IRS began with 1099 series forms, which have been supported on IRIS since 2022. The 1098 series is part of the second wave of forms migrating to IRIS, scheduled for completion before the December 31, 2026 deadline.

What Changes

For organizations that currently file 1098 forms through FIRE, several things will change:

• File format shifts from fixed-width text to XML. FIRE accepted rigid, column-based flat files. IRIS requires structured XML documents validated against published schemas. This is a significant technical change for any organization generating files in-house. For more on the format differences, see our IRIS XML format guide.
• FIRE TCCs become obsolete. Your existing Transmitter Control Code for FIRE will not work with IRIS. You will need a new IRIS-specific TCC if you file directly, or you can use an authorized provider like BoomTax and skip the TCC entirely. See the TCC differences between FIRE and IRIS for details.
• Submission method changes. Instead of uploading a single file through the FIRE web portal, IRIS offers three channels: a web-based taxpayer portal for manual entry, CSV template uploads for moderate volumes, and an A2A (Application-to-Application) API for automated high-volume filing.
• Validation happens differently. FIRE used batch processing with delayed error reporting. IRIS provides real-time validation and structured error codes, which means faster feedback but also a learning curve for teams accustomed to FIRE's error format.

What Stays the Same

The underlying reporting requirements for 1098 forms are not changing. The same information must be reported — payer TIN, recipient TIN, amounts, and form-specific fields. Only the delivery mechanism to the IRS is changing. Filing deadlines, dollar thresholds, and recipient copy requirements remain the same. Check the 2027 IRIS filing deadlines calendar for specific dates.

Timeline: When Will IRIS Support 1098 Forms?

The IRS has committed to supporting all information return types on IRIS before FIRE shuts down. For the 1098 series, here is what to expect:

Milestone	Expected Timing	Impact
IRS publishes 1098 XML schemas	2025–2026	Developers and vendors can begin building support
IRIS testing environment available for 1098	Mid-2026	Filers can validate their XML submissions
IRIS production filing opens for 1098	Late 2026	Live filing through IRIS begins
FIRE shuts down permanently	December 31, 2026	No more FIRE submissions accepted
First post-FIRE 1098 deadline	February 28, 2027	All 1098 filing must go through IRIS

For a comprehensive view of all form type transition dates, see the full FIRE-to-IRIS transition timeline.

What 1098 Filers Should Do Now

1. Verify Your Vendor's IRIS Readiness

If you use third-party software to generate or transmit 1098 forms, contact your vendor now and ask:

• Do they already support IRIS for 1098 filing?
• If not, what is their timeline for adding support?
• Will your existing data export format continue to work, or will you need to make changes?

Don't assume your vendor has this handled. Some smaller vendors may not have started IRIS development yet.

2. Understand the XML Format Change

If your organization generates Publication 1220-format files in-house — from a loan origination system, student information system, or custom reporting tool — you have a decision to make. You can either update your systems to produce IRIS-compliant XML, or you can use a service like BoomTax that converts your existing FIRE-format files to IRIS XML automatically.

3. Plan for the TCC Transition

If you file directly with the IRS, you will need an IRIS TCC. The registration process involves e-Services account setup, ID.me identity verification, and an IRS suitability review that can take 45+ days. Start this process early. Alternatively, use an authorized e-file provider and skip the TCC process entirely.

4. Consider Your Filing Volume

Large mortgage lenders and student loan servicers may file hundreds of thousands of 1098 forms annually. At that scale, the A2A API channel is the right choice for IRIS. Mid-volume filers may find the CSV upload sufficient. For a detailed guide on choosing the right approach, see our IRIS filing guide for banks and financial institutions or our guide for real estate organizations.

How BoomTax Handles 1098 Filing Through IRIS

BoomTax will support the full 1098 series through IRIS as soon as the IRS opens the channel. For BoomTax customers, the transition is seamless:

• Keep your FIRE-format files. If your loan origination or student information system currently generates Publication 1220 files, upload them to BoomTax as-is. BoomTax converts them to IRIS XML and submits them automatically.
• No TCC required. BoomTax maintains all necessary IRIS authorizations. You never need to apply for or manage your own TCC.
• No software changes. Your existing data export process continues unchanged. BoomTax handles the FIRE-to-IRIS translation layer.
• Same API. If you integrate with the BoomTax API, your integration continues working without modification.

Frequently Asked Questions

Next Steps

• Full details on the IRS FIRE system shutdown
• Step-by-step guide to migrating from FIRE to IRIS
• IRIS filing guide for banks and financial institutions
• IRIS filing guide for real estate organizations
• FIRE shutdown impact on 5498 filers
• Keep your FIRE files — let BoomTax handle IRIS